Issue and Options 2023

No

Bullet points one and five of the Vision objectives on page 21 of the SWLP (January 2023) state that: • “…A climate resilient and Net Zero Carbon South Warwickshire – adapting to the effects of climate change and mitigating against its causes, while avoiding any further damage that might arise from development. • A biodiverse and environmentally resilient South Warwickshire – strengthening green and blue infrastructure and achieving a net increase in biodiversity across South Warwickshire…” Lockley Homes response: A climate resilient and Net Zero Carbon South Warwickshire Whilst we support the principles behind the emerging Vision policy approach and the need to adapt to the effects of climate change and work towards achieving a Net Zero Carbon South Warwickshire it is important that any climate resilient and Net Zero Carbon objectives and targets included within the emerging SWLP are both realistic and capable of being delivered in accordance with guidance in paragraphs 16 (indent b) and 35 (indent c) of the Revised National Planning Policy Framework (NPPF) (2021). Paragraph 16 (indent b) is perfectly clear that: “…Plans should: (indent b) be prepared positively, in a way that is aspirational but deliverable…” NPPF (2021) paragraph 35 (indent c) confirms that: “…Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are: (indent c) Effective – deliverable over the plan period…” Focusing on the house building development industry, as stated above, whilst we support the principles behind the emerging Vision policy approach and the need to incorporate climate change mitigation features within new development proposals, incorporating these types of features can often significantly increase the financial build costs for new build residential schemes. At a time when the construction sector is already experiencing rapid and significant price increases in the financial costs of building materials, and increased labour costs. We would therefore advise that a pre-cautionary policy approach is therefore taken by the LPA’s preparing the emerging SWLP in relation to this issue, given the severe adverse set of economic circumstances now facing the local area, for reasons already set out within this wider Representations Statement document. Given the above issues, it is important to ensure that a less financially onerous planning policy regime is placed on housing building development industry going forward within the SWLP (2023) to help support the future financial viability of new housing development sites during the very fragile post-COVID-19 economic recovery. Lockley Homes maintains its view that its position on these matters is supported by guidance within paragraph 82 (indent d) of the Revised NPPF (2021) which confirms that: “…Planning policies should (indent d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices…, and to enable a rapid response to changes in economic circumstances…” The rapid and significant shift in adverse economic circumstances now facing the Local Plan area, should now be shaped into a heavily revised planning policy approach being taken forward by the LPA’s within the emerging SAP for the reasons highlighted above. A biodiverse and environmentally resilient South Warwickshire Lockley Homes is a developer of very high-quality new build luxury homes, and as a developer we take our environmental responsibility very seriously, and where opportunities exist, we are keen to support biodiversity within our new residential development schemes. We therefore suggest that the Vision and Strategic Objectives of the emerging SWLP could be significantly strengthened and improved from a nature conservation new habitat creation planning policy perspective, by emphasising the important role that new housing development sites/ proposals can play in helping to promote and deliver new on-site nature conservation habitat features, integral for helping to support the delivery of Biodiversity Net Gain (BNG) across South Warwickshire. These issues are already considered in further detail within this wider Representations Statement.

The Sustainability Appraisal (SA) being used to support the emerging SWLP (2023) is not promoting the most sustainable patterns of new housing development to the most sustainable site locations within the South Warwickshire Region. Stratford-on-Avon District Council’s Planning Policy Team is showing a very strong level of support and notably biased favouritism towards significantly less sustainable site locations by prioritising the delivery of new housing development sites located in isolated and very peripheral farmland locations. Distantly located away from the main existing village settlement cores, in areas of distantly located farmland countryside, on the very outer fringes and periphery of existing rural village settlements. The Council’s unreasonable and highly obstructive planning policy position and approach on this issue fails the ‘Sustainability’ Local Plan test of ‘Soundness,’ as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021) as referred to below. On this basis, both the accompanying Sustainability Appraisal (SA) being used to support Local Plan-preparation, and the emerging SWLP (2023), are both in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for Local Planning Authorities (LPA’s) to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Competent LPA’s should be aware of this NPPF guidance and its critical importance to Local Plan-making. The position is perfectly, this highly obstructive planning policy approach and ongoing failure and continued incompetence being taken towards Local Plan-preparation, means that the emerging SWLP Local Plan Review (2023), even at this very early stage in its Local Plan preparation, is already currently failing the ‘Sustainability’ test for Local Plan preparation tests of ‘Soundness’, as set out within paragraph 35 (indent d) of the Revised NPPF (2021). The emerging SWLP Local Plan Review (2023), alongside its sister document Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP), are both therefore vulnerable to future Legal challenge at the later Examination in Public (EIP) stage. Given their continued failure and ongoing refusal to promote the most sustainable patterns of new housing development across the South Warwickshire Region. It is important that these ongoing failings discussed above are now addressed within the emerging SWLP Review and its remaining Plan-preparation stages. We have fundamental planning policy concerns in relation to proposed new housing development and new employment land growth options and proposed site allocations being brought forward through the emerging SWLP Review given that these growth options are still continuing to force through an unreasonable, unsound and inflexible set of policies and an inflexible spatial planning policy framework approach by continuing to use the existing planning policy approach already set out and fixed within Stratford-on-Avon District Council’s existing adopted Development Plan – The Stratford-on-Avon District Core Strategy (2011 – 2031) (adopted July 2016). The year 2016 Core Strategy is now a long out-of-date Plan which is based on a heavily out-of-date pre-COVID-19 economic data, and an unsound set of supporting background technical evidence base documents, and unsound spatial planning policy modelling assumptions (based upon a heavily out-of-date economic landscape that existed over 8 years ago). These components are all no longer relevant and fit-for-purpose for future Plan making purposes – particularly given the shelf life timeframe of the SWLP, extending up until the year 2050! The Council’s preparing the emerging SWLP Review and its sister document - Stratford-on-Avon District Council’s emerging SAP (2023), are taking forward a highly inflexible and obstructive planning policy approach by refusing to accept proposed new housing site locations that are not already on the agreed list/ closed list of sites previously agreed by the year 2016 Core Strategy referred to above. Despite the fact that these proposed new housing site allocations, such as the Lockley Homes proposed housing allocation site, are in far more sustainable site locations in comparison to many of the housing site allocations being carried over from the year 2016 adopted Core Strategy. The position is perfectly clear, the Council’s are failing to promote the most sustainable patterns of new housing development, in direct conflict with a range of NPPF guidance already referred to within this wider Representations Statement. The emerging Sustainability Appraisal (SA) being used to support SWLP Plan-preparation has failed to take onboard these fundamental issues and therefore fails the tests of ‘Soundness’ as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). These issues are already considered within this wider SWLP Representations Statement (2023), as well as our extensive Representations already made to Stratford-on-Avon District Council’s emerging SAP, and the earlier SWLP ‘Scoping and Call for Sites Report’ (May 2021) (Regulation 18) public consultation. We have concerns that the Council’s are still failing to grasp these important issues, which are fundamental to the Soundness and Legal compliance (NPPF – para 35) of the emerging SAP and SWLP Local Plan Reviews.

Q-I2: We do not agree with any of the potential options described above. The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021). For reasons already set out within this wider Representations Statement (2023), we also object to the Council’s proposed Local Plan-making approach of producing a Stage 1 and Stage 2 (Parts 1 and 2) of the SWLP. This will just add a significant time delay to Local Plan delivery across the South Warwickshire Region, at a time when the local economy is facing such considerable economic uncertainty. This does not bode well for the delivery of a certain and clear planning policy framework going forward across the South Warwickshire Region. Placing small-scale and mediums scale housing sites within a Stage 2 SWLP is also completely unacceptable, and this proposed planning policy approach is in direct conflict with paragraphs 60 and 69 of the Revised NPPF (2021). Paragraph 69 of the Revised NPPF places considerable importance on small and medium-sized housing sites and their important contribution towards meeting the housing requirement of an area, and the fact that these sites are often built-out relatively quickly to help meet the urgent housing needs. Q-I3: Page 31 of the SWLP consultation report (January 2023) states that: “…To support the infrastructure requirements set out within the Local Plan, an Infrastructure Delivery Strategy will be prepared which will set out the key pieces of new infrastructure and the climate resilience of infrastructure needed to deliver the Plan and how this will be delivered. It will be necessary to ensure that developer contributions do not undermine the deliverability of the Plan, to this end the Plan will be informed by robust delivery and viability studies to assess the impact of infrastructure requirements…” Lockley Homes response Lockley Homes maintains its view that there has been a huge, substantial, unprecedented and significant recent material change, and a huge and rapid shift in highly damaging adverse economic circumstances now facing the South Warwickshire Region and the wider United Kingdom, due to the presence of the ongoing global coronavirus pandemic (COVID-19), economic uncertainty caused by Russia’s Spring 2022 invasion of Ukraine, and the subsequent severe and unprecedented economic downturn. Which is anticipated to cause one of the worst economic recessions in the UK in living memory since records began. The severity of the forthcoming recession is now acknowledged by central Government (London), who accept that the COVID-19 pandemic has caused one of the worst economic recessions within the UK not seen for the last 300 years. This is highly significant, and should now result in an urgent re-shaping of affordable housing, Community Infrastructure Levy (CIL), planning obligations, and infrastructure policies within the Council’s emerging Local Plan Review. The Council’s preparing the emerging SWLP and its sister document Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) now need to begin to finally accept that their highly onerous planning policy position on these policy issues now needs to change to help support the highly fragile local economic recovery, and help support the house building development industry at a time when they are trying to bring forward sites under an incredibly challenging economic climate, which will affect the financial viability of many housing schemes. A highly onerous affordable housing and CIL/ planning obligations/ infrastructure demands approach therefore needs to be avoided within the emerging Local Plan Reviews referred to above. The worst global health pandemic event to affect the UK for the last 100 years, combined with the presence of one of the most severe economic recessions for the last 300 years, should now result in a more supportive Development Management and Planning Policy approach being taken (to support the interests of the private sector development industry and rural landowners) by the LPA within the emerging SAP and SWLP Reviews in relation to unreasonable and highly onerous affordable housing planning policy requirements, Community Infrastructure Levy (CIL) planning policy requirements, and other infrastructure demands/ planning policy requirements being placed on the house building development industry, the local business community and rural landowners looking to bring forward sustainably-located new housing development sites. In order to help support the future financial viability of new housing development schemes coming forward across the district at an incredibly challenging time, and to help support the fragile post Covid-19 local economic recovery across the South Warwickshire Region. This approach would be consistent with Government guidance reinforced within paragraph 82 (indent d) of the Revised NPPF (2021) which confirms that: “…Planning policies should (indent d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices…, and to enable a rapid response to changes in economic circumstances…” The evidence is perfectly clear, all of the above ‘pandemic-related’ factors appear to have been given an insufficient level of planning policy consideration and material planning weight whatsoever by the LPA’s when preparing the Council’s emerging Site Allocations Plan (SAP) and emerging South Warwickshire Local Plan (SWLP). We have concerns about this ongoing failure and continued incompetence being taken towards Local Plan preparation within the South Warwickshire Region. These critically important ‘pandemic-related factors’ described above therefore require critical consideration by Stratford-on-Avon and Warwick District Council’s Planning Policy Teams as part of their ongoing Plan-preparation work going forwards. To ensure that the Council’s planning policy approach is sufficiently robust, based on a platform of credible and fit-for-purpose evidence, and responds effectively to guidance in paragraphs 31, 35 (indents b and c) and 82 (indent d) of the Revised NPPF (2021). The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021). The Council’s preparing the above referred to Local Plan Reviews cannot continue to load and place unreasonable planning policy demands and requirments onto the house building development industry for the reasons explained above. A heavily revised planning policy approach is therefore urgently needed to allow the Council’s Plan-making approach to respond effectively to the above NPPF guidance.

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Q-S3.2: Lockley Homes would select Option S3.2c (None of these) given that the other options listed above fail to recognise the importance of sustainably located greenfield sites, and the important role that they can play in delivering new housing. We maintain our view that our site within the Village of Broom settlement should be brought forward as a matter of urgency within the SWLP Review (2023). The strong set of sustainability credentials of the Lockley Homes site is supported by robust and defendable evidence as set out in Appendix B of this Representations Statement. As a key local stakeholder, we have continued concerns that the Council’s preparing the emerging SWLP Review are ignoring the potential important role that under-utilised low quality greenfield sites, which have strong physical connections to long established existing village settlements, can play in helping to meet longstanding housing shortfalls present across the SWLP Local Plan area to help meet the development needs up until the year 2050. The Council’s unreasonable and highly obstructive planning policy position and stance being taken towards these types of sites fails the ‘Sustainability’ Local Plan test of ‘Soundness,’ as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). There is a severe shortage of brownfield sites (previously developed land) available across the SWLP area to meet identified housing needs and longstanding housing shortfalls, given that the SWLP districts are both dominated by open countryside. Therefore, the important role and contribution that low quality, under-utilised green space areas (such as former paddock land), in well-integrated locations within the confines of existing village settlements can make towards housing supply should be increasingly recognised by the LPA’s preparing the emerging SWLP. Our views on this issue are supported by an extensive range of guidance from the Revised NPPF (2021). Most notably, paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for Local Planning Authorities (LPA’s) to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Competent LPA’s should already be aware of this NPPF guidance and its critical importance to Local Plan-making. The position is perfectly, this highly obstructive planning policy approach, ongoing failure, continued refusal and continued incompetence being taken towards Local Plan-preparation by the Council’s Planning Policy Teams, means that the emerging SWLP Local Plan Review (2023), even at this very early stage in its Local Plan preparation, is already currently failing the ‘Sustainability’ test for Local Plan preparation tests of ‘Soundness’, as set out within paragraph 35 (indent d) of the Revised NPPF (2021). The emerging SWLP Local Plan Review (2023), alongside its sister document Stratford-on-Avon District Council’s unsound and not-fit-for-purpose emerging Site Allocations Plan (SAP), are both therefore vulnerable to future Legal challenge at the later Examination in Public (EIP) stage. Given their continued failure and ongoing refusal to promote the most sustainable patterns of new housing development across the South Warwickshire Region. It is important that these ongoing, long-standing failings discussed above are now addressed within a revised planning policy approach being taken forward within the emerging SWLP Review, at its remaining Plan-preparation stages. As a key stakeholder, it is important that we highlight these failings to help strengthen the approach being taken towards future Local Plan making, to help the Council’s deliver a ‘Sound’ and ‘Legally compliant’ Local Plan, which meets the various tests of Soundness as set out within paragraph 35 of the Revised NPPF (2021). Q-S4.1: Yes, the growth of some of the existing settlements should be part of the overall strategy. This approach would correspond well with guidance in paragraph 79 of the Revised NPPF (2021). Paragraph 79 of the Revised NPPF (2021) states that: “…To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby…” In accordance with the above NPPF guidance, Lockley Homes would suggest that the Council’s emerging SWLP (2023) should consider the future housing-led growth and sustainable expansion needs of existing rural village settlements located across the South Warwickshire Region. This matter should be one of the key spatial planning policy priority areas for the emerging SWLP Review to consider, in order to help deliver a ‘More Positively Prepared Local Plan,’ and to allow the Plan to promote the most sustainable patterns of development - consistent with the ‘Sustainability’ tests of Soundness for Local Plan preparation as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). Proposed housing sites such as the Lockley Homes site located within the Village of Broom settlement should be brought forward for new housing development in the SWLP as a matter of urgency, not left for consideration within a future Stage 2/ version 2 of the SWLP in many years from now. We have ongoing concerns that the Council’s preparing the emerging SWLP and its sister document – Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP), are failing to promote the most sustainable patterns of new housing development within these Local Plan Reviews. This will mean that the Plans are vulnerable to future Legal challenge as they are both failing to comply with the Sustainability test as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). The position is quite clear, substantially less sustainable new housing development site locations are being strongly favoured by the LPA’s and strongly promoted, whilst more sustainable site locations are being completely ignored and overlooked by the LPA’s preparing the above Local Plan Reviews. We have concerns about this ongoing failure and continued incompetence being taken towards Local Plan preparation. Lockley Homes maintains its view that new housing development sites coming forward within the Stratford-on-Avon District and wider South Warwickshire Region within the most sustainable site locations, should be strongly encouraged, prioritised for new housing development first, before other less sustainable site locations are allocated for new housing, and should be considered very favourably within the emerging Local Plan Review process without unnecessary delay. To help meet the urgent housing needs of local communities within the South Warwickshire Region, and to help pro-actively address long-standing housing shortfalls present across the SWLP area. This approach accords strongly with current Government policy which is now governed by a pro-growth National Planning Policy Framework which gives a presumption in favour of sustainable development, and guidance in paragraph 60 of the Revised NPPF (2021) which emphasises the need for LPA’s to significantly boost the supply of new homes across the United Kingdom. General comments: The Sustainability Appraisal (SA) being used to support the emerging SWLP (2023) is not promoting the most sustainable patterns of new housing development to the most sustainable site locations within the South Warwickshire Region. Stratford-on-Avon District Council’s Planning Policy Team is showing a very strong level of support and notably biased favouritism towards significantly less sustainable site locations by prioritising the delivery of new housing development sites located in isolated and very peripheral farmland locations. Distantly located away from the main existing rural village settlement cores, in areas of distantly located farmland countryside, on the very outer fringes and periphery of existing rural village settlements. The Council’s unreasonable and highly obstructive planning policy position and approach being taken on this issue fails the ‘Sustainability’ test of ‘Soundness’ for Local Plan preparation, as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). On this basis, both the accompanying Sustainability Appraisal (SA) being used to support Local Plan-preparation, and the emerging SWLP (2023) are both in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for LPA’s to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Our concerns on these issues are already covered within this wider SWLP Representations Statement (March 2023), as well as our Representations to Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) (2022). Q-S10: We have concerns that the LPA’s preparing the emerging SWLP Review (2023) are failing to promote the most sustainable patterns of new housing development across the South Warwickshire Region. Lockley Homes maintains its view that the Council’s preparing the emerging SWLP Review (2023) should be focusing new housing development proposals towards sustainably-located infill sites within and on the edge of existing rural village settlements, in accordance with guidance in paragraph 79 of the Revised NPPF (2021). Lockley Homes has a perfectly acceptable site location suitable for new housing development. For reasons already set out within this wider SWLP Representations Statement (March 2023), this site should be supported within the emerging SWLP Review, not left for a future Stage 2 of the SWLP Local Plan to consider in many years from now. Stratford-on-Avon District Council’s Planning Policy Team is showing a very strong level of support and notably biased favouritism towards significantly less sustainable site locations by prioritising the delivery of new housing development sites located in isolated and very peripheral farmland locations. Distantly located away from the main existing rural village settlement cores, in areas of distantly located farmland countryside, on the very outer fringes and periphery of existing rural village settlements. The Council’s unreasonable and highly obstructive planning policy position and approach being taken on this issue fails the ‘Sustainability’ test of ‘Soundness’ for Local Plan preparation as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021). As well as an extensive range of other guidance from the Revised NPPF. Most notably, paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for LPA’s to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Our concerns on these issues are already covered within this wider SWLP Representations Statement (March 2023), as well as our Representations to Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) (2022).

Yes

Within the supporting background technical evidence base document titled “Heritage and Settlement Sensitivity Assessment” we have concerns that the Village of Broom settlement (located within the western part of the Stratford-on-Avon District) has been recognised as having high historic environment sensitivity. We would strongly object to these planning policy assumptions. We object to the continued poor quality of the evidence base being used to support Local Plan-preparation. Furthermore, in order to deliver “a More Positively Prepared Local Plan” in accordance with the tests of Local Plan Soundness as reinforced within paragraph 35 (indent a) of the Revised NPPF (2021), the Council’s preparing the emerging SWLP (2023) should not view heritage designations as a site constraint to prevent new housing-led development proposals from coming forward. Given that high-quality new residential development schemes incorporating good architectural design features, and use of appropriate and sympathetic types and colours of building materials in external facing building facades (which remain sympathetic to preserving a proposal sites historic surroundings), can all help to improve the historic setting, appearance and character of both Statutory Listed Buildings (such as Grade II Listed buildings), and adjacent Conservation Areas. Historic environment focused guidance in the Revised NPPF (2021), positively encourages new development proposals which seek to enhance the character and setting of the historic environment. This is confirmed in paragraphs 190 (indent c) and 197 (indent c) of the Revised NPPF (2021), which both strongly encourage new development proposals which seek to “…make a positive contribution to local character and distinctiveness…” The presence of heritage designations should therefore not be viewed as a site constraint, to prevent future new housing development sites from coming forward within the emerging Local Plan area. We have concerns that the historic environment policies being taken forward within the emerging SWLP Review are unduly onerous, highly restrictive, are not sufficiently robust, and lack sufficient ambition, and therefore fail to reflect the above NPPF guidance. As already stated within our wider Representations within this Local Plan Representation, it is important that any heritage designations and any heritage assessments being used by Local Planning Authorities to inform future Local Plan preparation work are supported by a sufficiently robust and defendable platform of up-to-date evidence - consistent with guidance reinforced within paragraphs 31, 35 (indent b) and 192 of the Revised NPPF (2021).

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Q-S5.2: - We consider that new settlements should be part of the overall strategy. However, we have concerns that the Council’s preparing the emerging SWLP are overlooking more sustainable site locations for new housing development, and prioritising less sustainable site locations for new housing development. This matter is discussed below and within our wider SWLP Representations Statement (March 2023). Q-S5.3: As well as focusing new housing development alongside existing rail corridors, the LPA’s should also consider focusing new housing development near to public transport bus services routes. Development sites within existing settlements should also be strongly pursued, such as the Lockley Homes large infill site located within the Village of Broom settlement, within the western part of the Stratford-on-Avon District. The focus of the emerging Local Plan is currently far too narrow, just to focus solely on rail corridors, and will fail to meet the objectives of paragraphs 60 (boost the supply of housing) and 79 (focus new housing development towards existing rural village settlements) of the Revised NPPF (2021). As stated, far too much priority is being placed on the importance of rail corridors – which fails to deliver “a More Positively Prepared Local Plan” in line with paragraph 35 (indent a) of the Revised NPPF (2021). Site locations with good access to bus routes and site locations located adjacent to existing rural village settlements should be afforded significantly more planning policy weight and should be considered as favourable locations for new housing development. This planning policy approach has considerable planning policy support in paragraph 79 of the Revised NPPF (2021) which confirms that: “…To promote sustainable development in rural areas, housing should be located where it would enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive…” To help effectively address the Climate Change Emergency within the South Warwickshire Region, the types of site locations recommended by paragraph 79 of the Revised NPPF (2021) should be urgently prioritised for new housing development by the LPA’s preparing both the emerging SWLP and SAP Local Plan Reviews. As a key local stakeholder and developer of very high quality residential schemes, we have continued concerns that both the emerging SWLP and its sister document Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP), are both failing to promote the most sustainable patterns of new housing development across the South Warwickshire Region, in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021) – which all reinforce the need for Local Planning Authorities (LPA’s) to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. Competent LPA’s should already be aware of this NPPF guidance and its critical importance to Local Plan-making.

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The new emerging SWLP timeframe will extend from potentially the years 2030 up until the year 2050. In terms of meeting housing shortfalls from elsewhere and deciding where to focus this new housing development within the emerging SWLP area, the future housing development growth needs of existing rural village settlements across the SWLP Plan area, and the new housing-led development expansion needs of these existing rural village settlements will therefore require careful consideration given the considerable timeframe of the new Local Plan, extending up until the year 2050. Existing village settlements, such as the Village of Broom, should therefore be given very high priority, and should be urgently prioritised for new housing development. This matter should not be left for a Stage 2/ version 2 of the SWLP Review to consider in many years from now, but should be prioritised as a matter of urgency now within the January 2023 SWLP. In particular, in terms of considering how these existing rural village settlements (like the Village of Broom) can grow and thrive over the new Local Plan period by bringing forward sustainably located new housing development sites, such as the sustainably located Lockley Homes site currently being promoted through the emerging SWLP. The future growth and sustainable expansion needs of existing rural village settlements across the SWLP area will therefore require careful planning policy consideration to help shape their future development needs up until the year 2050. Particularly, the sustainable expansion of existing rural village settlements on the edges of their existing boundaries with new housing, the policy approach strongly promoted by guidance in paragraph 79 of the Revised NPPF (2021) as considered below. As this spatial planning approach can help to sustain the vitality of existing rural village settlements with new sustainably located housing, allowing them to grow and thrive over the future years. Paragraph 79 of the Revised NPPF (2021) states that: “…To promote sustainable development in rural areas, housing should be located where it would enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive…” Before promoting ‘free-standing’ sites located within the open countryside, including those ‘free-standing’ sites located within the existing designated Green Belt countryside, the emerging Stratford-on-Avon District Council emerging Site Allocations Plan (SAP) (Review) (2023) and Stratford-on-Avon and Warwick District Council’s emerging South Warwickshire Local Plan (SWLP) Reviews should be strictly prioritising the delivery of new housing development sites within sustainably-located large infill sites (located outside of the designated Green Belt), located within existing rural village settlements. And prioritising the delivery of new housing development within areas of farmland located on the edges of existing rural village settlements. The evidence is perfectly clear, this approach to Plan-making is strongly supported by guidance reinforced within paragraphs 11, 35 (indent d), 79, 120 (indent d), 141 (indent a), 142 and 149 (indent e) of the Revised NPPF (July 2021). To follow a different Plan-making approach would fail the ‘Sustainability’ tests of Soundness for Local Plan preparation as reinforced within paragraph 35 (indent d) of the Revised NPPF (2021), and would make the emerging SAP and SWLP Local Plan Reviews, and any supporting background technical evidence base being used to accompany Plan-preparation, insufficiently robust, and therefore vulnerable to future Legal challenge at the later Local Plans Examination in Public (EIP) stages. We have concerns about the longstanding failings being taken towards Local Plan preparation within the Stratford-on-Avon District on these matters, and Stratford-on-Avon District Council’s constant ongoing refusal to promote the most sustainable patterns of new housing development within the Stratford-on-Avon District. We have concerns about the “incapable” management and leadership approach being taken towards Local Plan preparation within the Stratford-on-Avon District given the Council’s Planning Policy Teams continued refusal and ongoing failure to promote the most sustainable patterns of new housing development within the emerging SAP Local Plan Review (2023). This underlines the ongoing failure and continued incompetence being taken towards Local Plan preparation within the Stratford-on-Avon District. These ongoing failings are already covered in detail within our Representations to Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) (Review) (2022). Paragraph 120 (indent d) of the Revised NPPF (2021) confirms that: “…Planning policies and decisions should: (indent d) promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example converting space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure) …” Paragraph 141 (indent a) of the Revised NPPF (July 2021) underlines the importance and expects LPA’s to encourage the use of under-utilised land for new housing development. Such as low-quality green space areas and derelict and under-utilised former paddock land, located both within and bordering existing rural village settlements - in order to help promote the most sustainable site locations for new housing development. It emphasises that these highly sustainable site locations should be prioritised first for new housing development. Before LPA’s introduce changes to Green Belt boundaries and before LPA’s identify sites for new housing development within the Green Belt countryside. This spatial planning policy approach to Local Plan-preparation is required in order to help protect the Green Belt from development encroachment pressures, and to help promote sustainable patterns of development as stated above. It states that: “… Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy: (indent a) makes as much use as possible of suitable brownfield sites and under-utilised land…” Further support is provided in paragraph 142 of the Revised NPPF (2021) which is perfectly clear in its view that: “…When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policy-making authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land…” These types of highly sustainable infill site locations (see photographs 1 and 2 in Appendix B of this Representations Statement document (March 2023), should be strictly prioritised first as a matter of urgency for new housing development. Before LPA’s select unsustainable site locations for new housing development, located within areas of open Green Belt countryside. In free-standing new build housing settlements, located far away from existing rural village settlements, and far away from existing towns. Competent Local Planning Authorities should ensure that their emerging Sustainability Appraisals (SA’s), being prepared alongside/ to support emerging Local Plan Reviews, should take on board these critically important spatial planning policy considerations - consistent with guidance in paragraphs 11, 35 (indent d), 79, 120 (indent d), 141 (indent a), 142 and 149 (indent e) of the Revised NPPF (2021). This will help to ensure that Local Plan Reviews satisfy the Local Plan ‘tests of Soundness’ (Para 35 – indent d of the Revised NPPF (2021)) when these tests of soundness are being carefully examined at future Public Local Inquiries (PLI’s), as part of the Local Plan Review preparation stage. Lockley Homes maintains its view that it has a sustainably-located site suitable for new housing development, located within an existing rural village settlement boundary. Given the very strong, defendable, clear and compelling sustainability credentials of the site as already evidenced in our earlier Representations to both the SWLP and SAP Local Plan Reviews. We consider that this site, within the Village of Broom settlement boundary, should be prioritised for future development, and included without delay as a new housing site allocation on the main Policies Map of the emerging Local Plan Reviews referred to above. This site should also be strongly encouraged within the emerging background technical evidence base documents being used to support Local Plan preparation work across the South Warwickshire Region, given this sites very strong set of sustainability credentials. This is particularly evidenced in photographs 1 and 2 of Appendix B of this Representations Statement (March 2023). We consider that allocating this site for new housing development in the Council’s emerging SAP and SWLP as suggested, would result in a More Effective, Positively Prepared and Justified Plan, consistent with guidance in paragraph 35 of the Revised NPPF (2021).

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Q-H6: We neither agree with or support any of the proposed emerging Options on pages 117 and 118 of the SWLP (2023). Consistent with our earlier representations to the SWLP Draft ‘Scoping and Call for Sites Report’ (May 2021) (Regulation 18) public consultation, we have concerns about the proposed planning policy approach being taken towards gypsy and travellers and travelling showpeople accommodation needs within the South Warwickshire Region within the emerging SWLP (2023). Unsustainable levels of pitch numbers are being proposed across South Warwickshire Region which will promote inappropriate, damaging and unsustainable patterns of development within the local area, and cause significant residential amenity conflicts with the existing settled community, as well as damage sensitive rural landscapes and wildlife habitats, and place unreasonable pressures on already constrained local road networks, existing healthcare and welfare facilities and local schools. We consider that Stratford-on-Avon and Warwick District Council’s proposed planning policy approach being taken forward within the emerging SWLP (Regulation 18) (January 2023) report on this issue conflicts with the following guidance: • Paragraphs 7, 8, 10, 11 (indent a), 16 (indent a) and 35 (indent d) of the Revised NPPF (July 2021) (which all reinforce the need for LPA’s to promote sustainable patterns of development). • Paragraphs 4 (indent k),10 (indent e), 13 and 23 of the Department for Communities and Local Government (DCLG) ‘Planning policy for traveller sites’ (August 2015). The approach being taken towards Local Plan preparation within the emerging SWLP Review is failing the ‘Sustainability’ tests of Soundness for Local Plan preparation as set out in paragraph 35 (indent d) of the Revised NPPF (2021). • The scale and number of pitch requirements needs to be significantly reduced within the emerging SWLP Review (2023). Proposed pitch requirements area far too excessive and unreasonable. • We would strongly encourage the LPA’s preparing the emerging SWLP to revisit this issue and prepare a new Gypsy and Traveller Accommodation Assessment (GTAA) supporting background technical evidence base document to inform the Local Plan preparation, which contains more realistic, more appropriate and deliverable pitch numbers. The current GTAA is not fit for purpose and fails to respond effectively to the unique characteristics of South Warwickshire Region in terms of its special heavily rural countryside and historic landscapes. • This scale of growth in new high pitch numbers being proposed would appear to be more appropriate and suitable within a very large urban area rather than small, heavily rural districts. • The future expansion needs of these new pitches (those proposed gypsy and traveller sites allocations being brought forward through the emerging SWLP Review) and the worsening landscape impacts as they further expand and grow in future years within rural countryside has been given no planning policy consideration whatsoever by Stratford-on-Avon and Warwick District Council’s Planning Policy Teams. This underlines the ongoing failure and continued incompetence being taken towards this sensitive and critically important planning policy topic matter within the emerging SWLP Review. The one-size-fits-all naïve Planning Policy approach to Local Plan-preparation is causing huge levels of damage within the local area. • The sustainability implications of this huge scale of growth in new pitch numbers is highly concerning. • We have concerns about the “incapable” management and leadership approach being taken towards Local Plan-preparation by the Council’s Planning Policy Team with regards to gypsy and traveller Planning Policy matters. • The ‘level of scale of growth’ in new pitch numbers across the Districts being proposed is very concerning in terms of the impacts of this scale of growth on the District’s continued future tourism and historic environment offer, and potential for considerable adverse and damaging landscape impacts within areas of open heavily rural countryside, and areas of historic landscape. • These proposals will have long standing damaging economic impacts on the local tourism industry within the Stratford-on-Avon District during the post-COVID-19 fragile local economic recovery, at a time when the local economy is facing one of the worst economic recessions of a scale and severity not experienced for the last 300 years. The level of harm that the Council’s Planning Policy Teams policies on this matter is causing to local businesses which rely on tourism income is concerning. • The potentially considerable, adverse and highly damaging impacts of this proposed scale of growth on the Local Plan areas local distinctiveness and unique character. • Careful ongoing dialogue is required between the LPA and affected local communities within the South Warwickshire Region so this scale of growth in new pitch numbers can be more carefully considered with local communities in accordance with advice in paragraph 16 (indent c) of the Revised NPPF (2021). • The impacts of this proposed scale of growth on existing sensitive small rural village settlements which lack the range of services, facilities and highway infrastructure necessary to accommodate this proposed scale of growth in new pitch numbers. • The potentially huge, adverse and highly damaging residential amenity impacts on the existing settled community. • The damaging landscape impacts on the District’s heavily rural open countryside. • This scale of growth in new pitch numbers does not appear to be sustainable in a heavily rural area, dominated by very small rural village settlements, within areas of remote countryside. • In its current format and proposed planning policy approach, the position is perfectly clear, the emerging SWLP Issues and Options Stage Report (January 2023) is promoting inappropriate, damaging and unsustainable patterns of development within the local area, contrary to the above NPPF and DCLG guidance. • Lockley Homes particularly objects to any proposals to encourage new Gypsy and Traveller and Travelling Showpeople sites within the western part of the Stratford-on-Avon District, within areas of remote and isolated heavily rural countryside, within the vicinity of the Village of Broom and Bidford-on-Avon small village settlements. Given this areas heavily rural character, this wider location should be fully removed and excluded from the new gypsy and traveller sites search zone within the emerging SAP and SWLP Local Plan Reviews. • The Council’s Planning Policy position and stance on this matter, is having a damaging impact on the local area. The LPA appears keen and determined to promote unsustainable patterns of development across the district within the emerging SAP and SWLP Local Plan Reviews. • ‘Sustainability principles’ should underpin and form the planning policy backbone and should be at the heart of any site selection approach taken by the LPA in the both the emerging Local Plan Review (2022) and the Council’s background technical evidence being used to support Local Plan Policy, such as the GTAA. • More needs to be done to stop Stratford-on-Avon and Warwick District Council’s Planning Policy Teams from causing huge levels of environmental damage within the South Warwickshire countryside by introducing significant levels of inappropriate harmful urbanising gypsy and traveller development within areas of open countryside. Which will result in highly damaging and adverse impacts affecting the residential amenity of the existing settled community, as well as damage the area’s tourism offer and sensitive historic rural landscapes. Further comments re Q-H6: We neither agree with or support any of the proposed emerging Options on pages 117 and 118 of the SWLP (2023). Consistent with our earlier representations to the SWLP Draft ‘Scoping and Call for Sites Report’ (May 2021) (Regulation 18) public consultation, we have concerns about the proposed planning policy approach being taken towards gypsy and travellers and travelling showpeople accommodation needs within the South Warwickshire Region within the emerging SWLP (2023). We consider that Stratford-on-Avon and Warwick District Council’s proposed planning policy approach being taken forward within the emerging SWLP (Regulation 18) (January 2023) on this issue conflicts with the following guidance: • Paragraphs 7, 8, 10, 11 (indent a), 16 (indent a) and 35 (indent d) of the Revised NPPF (July 2021) - which all reinforce the need for Local Planning Authorities to promote the most sustainable patterns of development when preparing emerging Local Plan Reviews. • The scattered distribution of gypsy and traveller sites across a large area (including areas of open countryside) is promoting heavily unsustainable patterns of development, contrary to the above NPPF guidance. • The sustainability implications of this scale of growth in new pitch numbers is concerning. • Paragraphs 4 (indent k),10 (indent e), 13 and 23 of the DCLG ‘Planning policy for traveller sites’ (August 2015). • The ‘level of scale of growth’ in new pitch numbers across the South Warwickshire countryside being proposed within the emerging SWLP is very concerning in terms of the impacts of this scale of growth on the district’s historic rural landscapes, areas of natural green space, environment offer, and potential for considerable adverse and damaging landscape impacts within areas of open heavily rural countryside. • The damage to the areas local economy, such as the tourism industry. • The potentially considerable, adverse and damaging impacts of this proposed scale of growth on the Local Plan areas local distinctiveness and unique character, and sensitive rural landscapes. • We have concerns about the “incapable” management and leadership approach being taken towards Local Plan-preparation with regards to gypsy and traveller Planning Policy matters. • Careful dialogue is required between the LPA and affected local communities within the SWLP coverage area so this scale of growth in new pitch numbers can be more carefully further explored with local communities - in accordance with advice in paragraph 16 (indent c) of the Revised NPPF (2021), which reinforces that: “…Plans should (indent c) be shaped by early, proportionate and effective engagement between plan-makers and communities…” • The impacts of this proposed scale of growth on existing sensitive small rural village settlements which severely lack the range of services, facilities (schools, healthcare facilities, welfare facilities) and highway infrastructure necessary to accommodate this proposed scale of growth in new pitch numbers. • Both the emerging SWLP Local Plan (2023) and the accompanying Gypsy and Traveller supporting background technical evidence base are both promoting highly unsustainable patterns of environmentally damaging development across the South Warwickshire Region. • The potentially huge adverse and highly damaging residential amenity impacts on the settled community raises concerns has not been given sufficient material planning consideration within the emerging SWLP. • The highly damaging landscape impacts on the South Warwickshire Districts heavily rural open countryside. • The future expansion needs of these new pitches (allocated gypsy and traveller sites) and the worsening landscape impacts as they expand and grow in future years within rural countryside has all been given an insufficient level of Planning Policy consideration by the LPA’s. • This scale of growth in new ‘high pitch numbers’ being proposed would appear to be more appropriate and suitable within a large heavily urbanised area rather than a small, heavily rural Districts characteristic of South Warwickshire. • This scale of growth in new pitch numbers does not appear sustainable in a heavily rural area, dominated by small rural village settlements, within remote areas of countryside. • In its current format and proposed planning policy approach, the position is perfectly clear, the emerging SWLP (January 2023) is promoting inappropriate, damaging and unsustainable patterns of new gypsy and traveller development within the local area, contrary to the above NPPF (2021) and DCLG guidance. • ‘Sustainability principles’ should underpin and form the planning policy backbone and should be at the heart of any site selection approach taken by the LPA’s in the both the emerging SWLP Local Plan Review (2023) and the Council’s accompanying GTAA background technical evidence being used to inform and support Local Plan preparation. • More needs to be done to stop Stratford-on-Avon District Council’s Planning Policy Team from causing huge levels of environmental damage within the local area, by introducing significant levels of inappropriate harmful urbanising gypsy and traveller development within sensitive open countryside locations. Which will result in highly damaging and adverse impacts affecting the residential amenity of the existing settled community, as well as damage the area’s unique rural identity, tourism offer and historic countryside landscapes. Conclusion Unsustainable levels of pitch numbers are being proposed across South Warwickshire which will promote inappropriate, damaging and unsustainable patterns of development within the local area, and cause significant residential amenity conflicts with the existing settled community, as well as damage sensitive rural landscapes and wildlife habitats, and place unreasonable pressure loads on road infrastructure, existing healthcare and welfare facilities, and local schools. The Council’s SWLP ‘Issues and Options Stage Report’ (Regulation 18) (January 2023) is promoting both irresponsible and unsustainable patterns of development across the district’s, in direct conflict with the ‘Sustainability’ test of ‘Soundness’ for Local Plan preparation as reinforced within paragraph 35 (indents d) of the Revised NPPF (2021). Q-H7: Lockley Homes strongly objects to the Council's proposals to bring forward small and medium-sized housing sites within the proposed Stage 2 SWLP, and not Stage 1. Stage 1 is proposing to bring forward only major strategic housing site allocations. In accordance with paragraph 69 of the Revised NPPF (2021), smaller housing site allocations (smaller and medium-sized land parcels) should be brought forward as a matter of urgency, not left for many years ahead within a Stage 2 SWLP. Paragraph 69 of the Revised NPPF (2021) attaches importance to the urgent delivery of small and medium sized sites. It confirms that: “…Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. To promote the development of a good mix of sites local planning authorities should: (indent c) support the development of windfall sites through their policies and decisions – giving great weight to the benefits of using suitable sites within existing settlements for homes...” Lockley Homes maintains its view that new housing development sites coming forward within the South Warwickshire Region, within the most sustainable site locations, should be strongly encouraged and prioritised for new housing development first, before other less sustainable site locations are brought forward within the emerging Local Plan Review, and should be considered very favourably within the Local Plan Review process without unnecessary delay. In order to help meet the urgent housing needs of local communities within the South Warwickshire Region, and to help address continuing long-standing housing shortfalls present across the SWLP Local Plan area. This approach to Plan-preparation strongly accords with current Government policy which is now governed by a pro-growth National Planning Policy Framework, which gives a presumption in favour of sustainable development, and guidance in paragraph 60 of the Revised NPPF (2021), which emphasises the need for LPA’s to significantly boost the supply of new homes across the United Kingdom within the most sustainable site locations. The need for LPA’s to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews is reinforced within paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021). Competent Local Planning Authorities should already be aware of this NPPF guidance when preparing emerging Local Plan Reviews. In accordance with guidance reinforced in paragraph 79 of the Revised NPPF (2021), Lockley Homes would suggest that the Council’s preparing the emerging SWLP (2023) should consider the future housing-led growth and expansion needs of existing rural village settlements located across the South Warwickshire Region. This matter should be one of the key spatial planning policy priority areas for the emerging SWLP Local Plan Review to consider, as a matter of urgency, in order to help deliver a ‘More Positively Prepared Local Plan,’ and promote the most sustainable patterns of new housing development - consistent with guidance in paragraph 35 (indent a and d) of the Revised NPPF (2021), and to help the SWLP respond positively to requirements of paragraphs 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF discussed below. Paragraph 79 of the Revised NPPF (2021) is perfectly clear in its view that: “…To promote sustainable development in rural areas, housing should be located where it would enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive…” Paragraph 120 (indent d) of the Revised NPPF (2021) confirms that: “…Planning policies and decisions should: (indent d) promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively …” Paragraph 141 (indent a) of the Revised NPPF (2021) underlines the importance and expects LPA’s to encourage the use of under-utilised land for new housing development. Such as low-quality green space areas and derelict and under-utilised former paddock land, located both within and bordering existing rural village settlements, in order to help promote the most sustainable site locations for new housing development. It emphasises that these highly sustainable site locations should be prioritised first for new housing development, before LPA’s introduce changes to the Green Belt boundaries, and before LPA’s identify sites for new housing development within the existing designated Green Belt countryside. This spatial planning policy approach to Local Plan-preparation is required in order to help protect the Green Belt countryside from development encroachment pressures, and to help promote sustainable patterns of development as stated above. It states that: “… Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy: (indent a) makes as much use as possible of suitable brownfield sites and under-utilised land…” Further support for the Lockley Homes site is provided by paragraph 142 of the Revised NPPF (2021), which confirms that: “…When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policy-making authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport…” Highly sustainable infill site locations (within areas of under-utilised low quality green space (such as former paddock land), located outside of the designated Green Belt), which display strong physical connections to the existing village settlement core and main village High Street, characteristic of the Lockley Homes site (see robust and defendable photographic evidence in photographs 1 and 2 in Appendix B of this SWLP Representations Statement), should be prioritised first as a matter of urgency for new housing development. Before the LPA’s preparing the emerging SWLP Review select unsustainable site locations for new housing development. Located within areas of open Green Belt countryside, in free-standing new housing settlements, located far away from existing rural village settlements, and far away from existing towns. Competent Local Planning Authorities should already be aware of above various NPPF guidance, and the need to promote the most sustainable patterns of new housing development when preparing emerging Local Plan Reviews. We have ongoing concerns about Stratford-on-Avon District Council’s Planning Policy Teams unwillingness, ongoing failure and continued refusal to wanting to promote the most sustainable patterns of new housing development across the Stratford-on-Avon District (such as the sustainably-located Lockley Homes site) within the emerging Local Plan Review. This highly obstructive planning policy approach, and ongoing failure and continued incompetence being taken towards Local Plan-preparation, means that the emerging SWLP Local Plan Review (2023), even at this very early stage in its Local Plan preparation, is already currently failing the ‘Sustainability’ test for Local Plan preparation tests of ‘Soundness’. As set out within paragraph 35 (indent d) of the Revised NPPF (2021). The emerging SWLP Plan (2023), alongside its sister document Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP), are both therefore vulnerable to future Legal challenge at the later Examination in Public (EIP) stage. Given their continued failure and ongoing refusal to promote the most sustainable patterns of new housing development across the South Warwickshire Region. As a key local stakeholder, we are just needing to highlight these critically important Local Plan ‘Soundness’ issues to try and help the Council’s Planning Policy Team improve its approach to future Local Plan making. For the reasons set out within this response, we have concerns about the “incapable” management and leadership approach being taken towards Local Plan preparation within the Stratford-on-Avon District As stated above, we have particular concerns in relation to the Planning Policy approach being taken towards Local Plan preparation within Stratford-on-Avon District Council’s emerging Site Allocations Plan (SAP) (2022/ 2023). Given that the Council throughout the various SAP Plan-preparation stages is continuing to overlook more sustainable site locations for new housing development, which are located outside of the existing designated Green Belt, and which have good strong physical connections to existing rural village settlement cores. Such as the sustainably-located Lockley Homes site – supported by robust and defendable photographic evidence in Appendix B of this SWLP Representations Statement. Stratford-on-Avon District Council’s Planning Policy Team is showing a very strong level of support and notably biased favouritism towards these significantly less sustainable site locations by prioritising the delivery of new housing development sites located in isolated and very peripheral farmland locations. Distantly located away from the main existing village settlement cores, in areas of distantly located farmland countryside, on the very outer fringes and periphery of existing rural village settlements. This incompetent approach being taken towards Local Plan preparation within the Stratford-on-Avon District is in direct conflict with paragraphs 7, 8, 10, 11 (indent a), 35 (indent d), 38, 79, 120 (indent d), 141 (indent a) and 142 of the Revised NPPF (2021). Which all expect LPA’s to promote the most sustainable patterns of new housing development when preparing Local Plan Reviews. This underlines the ongoing failure and continued incompetence being taken towards Local Plan preparation within the Stratford-on-Avon District by the Council’s Planning Policy Team. Our concerns on these issues are already covered in extensive detail within our earlier Representations to Stratford-on-Avon District Council’s emerging SAP. It is important that these ongoing failings discussed above are now addressed within the emerging SWLP Review, and its remaining ongoing Plan-preparation stages.